Affordability Checks
Request
In relation to affordability checks:
Credit Rating: What is considered a satisfactory credit rating under these assessments? Specifically, what exact credit score would a customer need to pass these affordability checks?
Length of Credit History: How many years of credit history are operators expected to review during these checks?
CCJs and other data: Are the affordability checks based solely on credit score and the length of credit history, or do they also include factors such as accounts in arrears or past/current County Court Judgments (CCJs)?
Data sharing: Will gambling operators be required to share data with credit reference agencies or other relevant parties to prevent individuals from using multiple gambling providers to bypass or exceed the £500 threshold?
Enforced Open Banking: Does this mean the Gambling Commission plans to mandate the use of Open Banking for gambling operators?
Credit Invisible Gamblers: If a customer or gambler does not consent to using Open Banking, will they effectively be blocked from gambling?
Additionally, regarding the frictionless financial risk assessments pilot, could you clarify how "different forms of data" will be evaluated for their relevance in the gambling context? What is the rationale for ruling out access to raw account-level data, and has the full potential of Open Banking been thoroughly explored?
Open Banking could allow for more comprehensive affordability assessments, and some critics have suggested it should be reconsidered for broader use. Would you be ready to respond to this line of argument?
Response
Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).
In your email you have requested the following information in relation to affordability checks:
Credit Rating: What is considered a satisfactory credit rating under these assessments? Specifically, what exact credit score would a customer need to pass these affordability checks? Length of Credit History: How many years of credit history are operators expected to review during these checks?
CCJs and other data: Are the affordability checks based solely on credit score and the length of credit history, or do they also include factors such as accounts in arrears or past/current County Court Judgments (CCJs)?
Data sharing: Will gambling operators be required to share data with credit reference agencies or other relevant parties to prevent individuals from using multiple gambling providers to bypass or exceed the £500 threshold?
Enforced Open Banking: Does this mean the Gambling Commission plans to mandate the use of Open Banking for gambling operators?
Credit Invisible Gamblers: If a customer or gambler does not consent to using Open Banking, will they effectively be blocked from gambling?
Additionally, regarding the frictionless financial risk assessments pilot, could you clarify how "different forms of data" will be evaluated for their relevance in the gambling context? What is the rationale for ruling out access to raw account-level data, and has the full potential of Open Banking been thoroughly explored?
Open Banking could allow for more comprehensive affordability assessments, and some critics have suggested it should be reconsidered for broader use. Would you be ready to respond to this line of argument?
The Commission has introduced financial vulnerability checks, initially at a higher threshold of £500 net deposits per 30 day rolling period at the end of August 2024 and at a lower threshold of £150 net deposit per 30 day rolling period in February 2025. A financial vulnerability check is designed to identify significant financial vulnerability at an early stage of the customer journey in order to be able to support customers who are significantly or particularly financially vulnerable. It is based on publicly available data and does not include credit reference bureau data. Full details of these checks are set out in our consultation response: Summer 2023 consultation – Proposed changes to LCCP and RTS: Consultation Response - Topic 4 - Financial vulnerability checks: Consultation Response and Financial risk assessments pilot: Consultation Response (gamblingcommission.gov.uk).
Financial risk assessments are not operating live. The Commission is conducting a pilot of frictionless financial risk assessments, in order to test how data sharing using credit reference data could be used to support high-spending gambling customers who are financially vulnerable and to inform a final decision on whether to introduce these assessments, and if so, how. Whilst often described as a an “affordability” check, this description is inaccurate. Instead, we are piloting a more targeted approach to identifying financial risk and difficulties.
We want to tackle cases where customers have been able to gamble large amounts without any checks or support where it was later identified that this led to significant harm. Our approach to the pilot is set out in our blog: Blog - Gambling Act Review implementation update (gamblingcommission.gov.uk). The pilot will explore the level of customer accounts for which a financial risk assessment can be conducted and the level of unmatched or thin files that would be in place. For these accounts, we will consider how alternative means of assessing financial vulnerability could be applied, including open banking. The Commission is not exploring enforced open banking as we do not consider this would align with the open banking approach, based on consent and transparency. We are also not exploring the use of preventing access to gambling should a customer choose not to share open banking details. However, all customers are subject to identity verification and some customer accounts may be subject to some form of check for either anti-money laundering or safer gambling reasons – if a customer chooses not to share any information to verify their identity or anti-money laundering/ safer gambling checks, it may not be possible to allow that customer to continue gambling.
We will continue to make available public information as our pilot progresses and the Commission’s full response of a decision following consultation and the pilot will also be published in due course.
Review of the decision
If you are unhappy with the service you have received in relation to your Freedom of Information request you are entitled to an internal review of our decision. You should write to FOI Team, Gambling Commission, 4th floor, Victoria Square House, Victoria Square, Birmingham, B2 4BP or by reply to this email.
Please note, internal review requests should be made within 40 working days of the initial response. Requests made outside this timeframe will not be processed.
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Information Management Team
Gambling Commission